RAJ PAL SINGH vs. COMMISSIONER OF INCOME TAX HARYANA

In the result, this appeal fails and is, therefore, dismissed

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

capital gains arose on the date of award, the High Court referred to various decisions on relating back, of the possession previously taken, to the date envisaged by the Act of 1894; and took guidance, inter alia, from the following enunciation by this Court in the case of Lt. Governor of Himachal Pradesh v. Avinash Sharma

THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

capital gain which could then be used to declare a special dividend to the shareholders of HTIL. We find no merit in this argument. 134. Firstly, the Tier I (Mauritius companies) were the indirect subsidiaries of HTIL who could have influenced the former to sell the shares of Indian companies in which event the gains would have arisen

M/S D. N. SINGH THROUGH PARTNER DUDHESHWAR NATH SINGH vs. COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

151 is alone applicable to the common carrier. The subject matter is not res integra. In Patel Roadways Ltd. v. 31 Birla Yamaha Ltd.9, the Court held inter alia as follows: - “31. Coming to the question of liability of a common carrier for loss of or damage to goods, the position of law has to be taken as fairly well

ISHIKAWAJMA-HARIMA HEAVY INDUSTRIES LTD. vs. DIRECTOR OF INCOME TAX, MUMBAI

The appeal is allowed in part and to

151,044,192 Treaty : Double Taxation Avoidance Agreement (DTAA) : Article 5 of the Double Taxation Avoidance Agreement (DTAA) between India and Japan, inter alia, provides as under : "1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

section 30 of the Copyright Act, which transfers an interest in all or any of the rights contained in sections 14(a) and 14(b) of the Copyright Act, but is a “licence” which imposes restrictions or conditions for the use of computer software. Thus, it cannot be said that any of the EULAs that we are concerned with

M/S. MANGALAM PUBLICATIONS, KOTTAYAM vs. COMMISSIONER OF INCOME TAX, KOTTAYAM

Bench: This Court & On Leave Being Granted, Civil Appeals Have Been Registered. 3.

151 of the Act, both pre 01.04.1989 and post 01.04.1989. He submits that there was admittedly non-disclosure of material facts by the assessee, and, therefore, the extended period under the proviso to Section 147 of the Act was available to the department. Viewed in the above context, the notices issued under Section 148 of the Act as well

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. AHMEDABAD URBAN DEVELOPMENT AUTHORITY

Bench: HON'BLE THE CHIEF JUSTICE

Section 12AA(1) of the IT Act, on 18.05.1979 and is engaged in the activity of promotion of the export of all kind of ready-made garments, knitwear, and garments made of leather, jute and hemp. It does not per se engage in any activity for profit, and its mandate is to ensure that Indian apparel manufacturers, are given forums